The defendant is charged [in count __]
with criminal mischief in the first degree. The statute defining this offense
reads in pertinent part as follows:

a person is guilty of criminal
mischief in the first degree when with intent to cause damage to any electronic
monitoring equipment owned or leased by the state or its agent and required as a
condition of (probation / conditional discharge / release / community release)1
and having no reasonable ground to believe that such person has a right to do
so, such person damages such electronic monitoring equipment and thereby causes
an interruption in its ability to function.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Damaged propertyThe first element is that the
defendant damaged electronic monitoring equipment owned or leased by the state
or its agent and required as a condition of (probation / conditional discharge /
release / community release).

Element 2 - Caused interruptionThe second element is that the
defendant caused an interruption in the functioning of the electronic monitoring
equipment. To cause means to bring about or to be a substantial factor, from
which the interruption follows as a natural, direct and immediate consequence.
The term "interruption" should be given its ordinary meaning.

Element 3 - IntentThe third element is that the
defendant intended to damage the electronic monitoring equipment. A person acts
"intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Element 4 - No rightThe fourth element is that the
defendant had no reasonable ground to believe that (he/she) had a right to
damage the property. A "reasonable ground to believe" means that a reasonable
person in the defendant's situation, viewing the circumstances from the
defendant's point of view, would have shared that belief.

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant damaged electronic monitoring
equipment owned or leased by the state or its agent and required as a condition
of (probation / conditional discharge / release / community release), 2) this
damage caused an interruption in the functioning of the electronic monitoring
equipment, 3) the defendant specifically intended to cause this interruption,
and 4) (he/she) had no reasonable ground to believe that (he/she) had a right to
damage the property.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
criminal mischief in the first degree, then you shall find the defendant
guilty. On the other hand, if you unanimously find that the state has failed to
prove beyond a reasonable doubt any of the elements, you shall then find the
defendant not guilty.
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1
For probation or conditional discharge, see § 53a-30; for release, see § 54-64a;
for community release, see § 18-100c.